Privacy and Cookie Policy

Please read the following privacy and cookies policy, in conjunction with our main terms and conditions, to understand how we use and protect the information that you provide to us.

In this policy:-

“Company” means Annandale Observer Limited, a company registered in Scotland with Company Number SC062879, and having its registered office at 96-98 High Street, Annan, DG12 6EJ, trading as DNG Media and “we”, “us” and “our” shall refer to the Company;

“Paywall” means a software barrier on the Website which restricts user’s access to certain functionality unless you have registered with the Website and paid a fee;

“Services” means any of the services provided by the Company through the medium of the Website, including but not limited to (a) provision of news stories and other information (b) advertising of cars, properties and various goods and services (c) advertising job vacancies, (d) provision of comment or discussion forums and (e) provision of competitions;

“Website” means any and all of the following websites published by the Company and located on the world wide web via the uniform resource locators:- www.dngonline.co.uk, www.annandaleobserver.co.uk, www.dumfriescourier.co.uk, www.annandaleherald.co.uk, www.moffatnews.co.uk, www.DnG24.co.uk and any other website of the Company;

“you” means any person who has viewed, downloaded, used or otherwise accessed the Website and/or Website Information and includes (but is not limited to) any person who has been granted access to a special area of the Website, and “your” shall refer to you.

The Company is committed to preserving the privacy of all visitors to the Website. We know that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly.

By using the Website, you consent to the collection, use and transfer of your information under the terms of this policy, including the use of cookies on the Website.

[Privacy Officer]

We have an appointed privacy officer (PO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the PO using the details set out below.

Our full details are:

Full name of legal entity: Annandale Observer Limited

Name of PO: Joanne Laidlaw

Email address:  privacy@dngonline.co.uk

Postal address: Privacy Officer, DnG Newspaper Group, 96 High Street, Annan, Dumfries & Galloway DG12 6EJ.

Telephone number: 01461 202417 or 01461 202078

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Information that we collect from you

When you register with the Website you will be asked to provide certain personal data or personal information about yourself including:

• Full name;

• Address;

• Telephone Number;

• Organisation Name;

• Email address; and

• Newsletter Subscription preferences.

(collectively “Contact Data”)

When you register with the Website and you which to use the extra functionality which is behind the Paywall we will require to also process:

• Billing Address;

• Payment method details;

• Bank account and payment card details; and

• transaction data (for example, details about payments to and from you and other details of Services you have purchased from us).

(collectively “Financial Data”)

Registration to the Website is completely optional and you are not obligated to register with the Website. Some of the functionality of the Website is behind a Paywall which requires you to register and pay to view and use.

We may also collect information about your usage of the Website as well as information about you from any messages you post to the Website and e-mails or letters you send to us or information gathered during telephone conversations with you.

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

This website is not intended for children and we do not knowingly collect data relating to children.

Use of your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us via email or phone or updating your preferences in your user account.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will get your express opt-in consent before we share your personal data with any company outside of our group of companies for marketing purposes.

Opting Out  

You can ask us or third parties to stop sending you marketing messages at any time by logging into you user account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Change of Purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The cookies we use allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.The cookies also record your vote in a Website poll and remember your preferences for viewing images.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below.

Please note that our advertisers may also use cookies, over which we have no control.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see below.

By continuing to browse the site, you are agreeing to our use of cookies.

Analytics

As you interact with our website, we may automatically collect: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website (“Technical Data”) about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Disclosure of your information

The information you provide to us will be held on our computers in the UK and may be accessed by or given to our staff, the staff of our group companies and third parties who act for us (who may work outside the UK) for the purposes set out in this policy or for other purposes approved by you. By submitting your information to us, you agree that it may be transferred outside the European Economic Area. We will always take steps to ensure that your information is used by third parties in accordance with this policy and the data protection laws of the UK.

We may also pass aggregate information on the usage of our Website to third parties but this will not include information that can be used to identify you.

If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.

We will not sell your biographical information or contact details to any third party. We will not share or distribute any of the information you provide to us with or to any third party unless as part of the service you have registered for, or we are required to do so by law, or we have obtained your consent to send you details about third party products and/or services, in which case we may pass the information you provide to us to the providers of those goods and/or services.

Security and data retention

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will not hold your personal data for more than a year after you remove/delete your user account with the Website unless we are required to under law.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include, the right to:

• request access to your personal data.

• request correction of your personal data.

• request erasure of your personal data.

• object to processing of your personal data.

• request restriction of processing your personal data.

• request transfer of your personal data.

• right to withdraw consent.

For more information on your rights please visit the Information Commissioner Officer’s website (www.ico.org.uk)

If you wish to exercise any of the rights set out above, please contact the PO on privacy@dngonline.co.uk or by phone on 01461 202417 or 01461 202078.

No Fee Usually Required  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to our privacy and cookies policy

Any changes to this policy in the future will be posted to the Website and/or, where we feel it is appropriate, notified to you by email.

Contact

All comments, queries and requests relating to our use of your information are welcomed and should be addressed to DNG Media, 96/98 High Street, Annan, DG12 6EJ or submitted to sg@dngonline.co.uk